EBA · 2021_6294 Rejected question

M 02.00, r0490 - SNP issued by EU small banks only

Regulation
Directive 2014/59/EU (BRRD)
Article
45i
Topic
BRRD Reporting
Submitted by
Credit institution
Submitted
2021-11-25
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Question

Should we limit our reporting to SNP issued by EU small banks only?

Background

In template M 02.00 (TLAC1), row 0490, it is expected to fill the subordinated debts issued by banks that are not GISB, nor EU D-SIBs. For EU small banks we can identify the rank Senior Non Preferred. For non EU non G SIBs banks, the eligibility to a TLAC/MREL-like ratio will be obtained by a structural or contractual subordination. Nevertheless we are not aware of the countries that have implemented a sort of TLAC/MREL for their medium/small banks.
No answer published yet.

Original source: European Banking Authority, Q&A ID 2021_6294

This Q&A is published by European Banking Authority and is non-binding. It does not constitute legal advice. Updated weekly from official ESA sources.

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